4. Options

Do nothing option

The "do nothing" option would mean failing to take action to
improve fire safety in Scotland's housing stock. Prior to the
Grenfell Tower tragedy, work was already underway through the
Common Housing Quality Standard Forum to harmonise housing
standards across tenures, including safety elements such as fire
and smoke alarm requirements in houses. This specific element has
now been prioritised to help minimise the risk of fire in
Scotland's homes.

Other options

Several options are proposed in the consultation paper
including:

A. Applying a higher standard to social rented housing
B. Applying a new standard to flats, irrespective of tenure
C. Applying a new standard to flats only in high-rise
buildings, irrespective of tenure
D. Applying a new standard to all housing, irrespective of
tenure

In each of these options, it is proposed that requirements are
in line with the standard currently applicable to the private
rented sector.

Current minimum standards in new build and private rented
housing require mains wired alarms. This is because of the risk
that alarms powered by disposable batteries will fail because
batteries have expired or been removed. The consultation also seeks
views on the option for types of sealed battery alarms where the
battery lasts the lifetime of the unit and is built with a
mechanism to alert the user that the alarm should be replaced.
Allowing these types of alarms would reduce the cost and disruption
associated with retrofitting mains powered alarms.

Views on each option are invited as part of the consultation
process.

Sectors and groups affected

Different proposals will affect different groups of people:

If additional fire and smoke alarm requirements are included
in the
SHQS, all
social housing providers and social tenants will be directly
affected.

If additional fire and smoke alarms are required in all in
tenements or blocks of flats, all owners and tenants living in
tenements or blocks will be directly affected.

If additional fire and smoke alarms are required in all
tenements and blocks of flats over 18 metres tall, all owners and
tenants living in such tenements and flats will be directly
affected.

If additional fire and smoke alarms are required in all
houses, all householders, including owners and tenants will be
directly affected.

Owners will incur costs if their current alarms fall short of
the new regulatory minimum. Occupants (owner-occupiers and tenants)
where fire and smoke alarms are installed will benefit from living
in homes which are safer and at lower risk of fire than they were
before the alarms were installed. Occupants of neighbouring
dwellings will also benefit from the reduced risk of fires which
spread to their homes.

Benefits

Reduced Number of Fatalities and Serious Injuries While the number of fatalities varies from year to year,
there is statistical evidence of a higher fatality rate for
dwelling fires in Scotland where no operational smoke alarm was
present. Over the seven years to 2015/16, there were 5.9 fatal
causalities per 1,000 dwelling fires where there was no operational
alarm, compared with 6.9 where there was an operational alarm.
[6] This lower fatality rate is in line with the international
evidence – a report by
BRE
Global for the Scottish Government found that a wide range of
international literature supports the conclusion that the presence
of an operational smoke alarm could reduce the risk of death by
50%.
[7]

Reduced Costs to Scottish Fire and Rescue Service The quicker response time associated with an alarm should
lead to a fall in the severity of fires to which the Scottish Fire
and Rescue Service are called. This is expected to lead to a
decrease in the amount of time and resources required from the
Scottish Fire and Rescue Service, reducing costs.

However, this must be set against a possible increase in costs
due to an increase in the number of false alarms to the Scottish
Fire and Rescue Service. Over the period 2009-10 to 2014-15, there
was a 29% increase in the number of false alarms due to the
apparatus, although this was followed by a small decline in
2015-16.
[8]

Reduction in Damage to Property The quicker response time due to an increase in the number
of smoke and fire alarms is expected to lead to a reduction in the
severity of fires, and, as a result, a decrease in the amount of
damage caused to property as a result of fires. A
UK Government report in
2004 estimated that the average amount of damage caused in a
residential fire in the
UK was £7,300.
[9] If this figure were simply uprated by inflation over the
period, this estimate would be approximately £9,000 for 2016
(however, any improvements in fire-fighting technology since 2004
may have served to decrease this figure).

Costs

If the same standard for fire alarms that applies to the private
rented sector is extended to other tenures, alarms will need to be
installed in properties which do not have any alarm as well as in
those which have one or more alarms but which fall short of the
required standard in terms of the number and placement of
alarms.

Although fire alarms are not mandatory in the owner occupied
sector, unless the property was built under the 1993 or subsequent
building regulations, only an estimated 7% (110,000) of properties
in this tenure do not have any smoke alarm at all.
[10] One third (490,000) have one alarm, while the remaining 60%
(900,000) have more than one alarm. The number of alarms prescribed
by the proposed minimum standard implies that the 600,000
owner-occupied properties with no or only one alarm definitely fall
below the proposed standard. Furthermore, it is possible that some
or most of the remaining 900,000 properties with more than one
alarm would also not comply with the proposed standard, although it
is not possible to determine the proportion from the available
data.

In the social rented sector, although at least one alarm is
required by the Scottish Housing Quality Standard, the estimated
48% (280,000) of properties with only one alarm would definitely
fall below the proposed standard. Again, it is likely that some or
most of the remaining 52% (305,000) of properties with more than
one alarm would fall the standard, although it is not possible to
determine this proportion.

In addition, most of the estimated 850,000 owner-occupied
properties and 140,000 social rented properties where the alarms
are only or partly powered by batteries are likely to require
replacement to comply with the standard, unless the battery type is
in compliance with the standard (a sealed battery unit designed to
last the lifetime of the fire alarm, which is at least 10
years).

Market figures indicate that a mid-range mains-powered,
inter-linked smoke alarm costs around £65 and that a
mid-range, inter-linked sealed battery alarm with a 10-year battery
life costs around £80. Installation of a mains-powered alarm
is likely to cost around £50, while sealed battery alarms do
not require professional installation.

As the proposal is currently for no alarm to be more than ten
years old, each property would incur the upfront purchase (and
installation costs where applicable) at least once every ten years.
Currently existing alarms will have a manufacturer's recommended
lifespan and this is usually ten years, but there is no process for
identifying or requiring replacement when the recommended lifespan
is exceeded.

The total cost to meet the requirements will depend on the final
form of the regulations and the built form of individual
properties.